Charles M. Ruchelman

"His strengths include the ability to speak about the law in layman's terms, strong follow-through, and an unbelievable attention to detail" - Chambers USA

"a great litigator, a good strategic thinker and an excellent advocate" - Chambers USA

Mr. Ruchelman is a Member in Caplin & Drysdale's Washington, D.C., office, where he concentrates his practice in tax litigation and controversies with the Internal Revenue Service and other tax authorities. He also represents clients in general tax matters.

Services

Mr. Ruchelman has extensive experience in resolving tax matters at all stages of tax disputes including IRS examinations, IRS appeals, post-appeals mediation, trial court litigation, and appellate litigation. He has litigated cases in the U.S. Tax Court, various U.S. district courts, and the U.S. Court of Federal Claims.

Building on his experience with the TEFRA partnership provisions,
Mr. Ruchelman has spent a significant amount of time studying, speaking on, and writing about the new IRS tax and collection procedures relating to partnerships and limited liability companies that were recently enacted under the Bipartisan Budget Act of 2015. Since enactment of the new statute, Mr. Ruchelman has spoken on panels with a Tax Court judge, government officials from the Treasury Department and IRS Office of Chief Counsel, as well as other practitioners before the American Bar Association, American Institute of CPAs, DC Bar Association, and Bloomberg/BNA.

Highlights

Currently representing numerous clients in all stages of Internal Revenue Service examinations and Government investigations involving foreign accounts and foreign entities.

Represented a hedge fund and its tax matters partner in a three-way IRS examination that led to litigation with the IRS and an adverse partner in the U.S. Court of Federal Claims (Imprimis Investors LLC v. United States, 83 Fed. CI. 46 (2008)).

Successfully defended Hawaii Department of Taxation and its employees against unlawful disclosure claims in the U.S. District Court (Marsoun v. United States, 525 F. Supp.2d 206 (D. D.C. 2007)).

Obtained a complete abatement and refund of over $600,000 of late filing, late payment, and late deposit penalties for multiple years for an oil services company relating to cross-border leasing payments and Form 1042.

Successfully resolved expatriation case, reducing over $2,000,000 in proposed tax and over $400,000 of penalties to less than $75,000 in tax and no penalties.

Government Experience

Before joining Caplin & Drysdale, Mr. Ruchelman was a Trial Attorney with the U.S. Department of Justice, Tax Division, and an Attorney with the Internal Revenue Service, Office of Chief Counsel.

While at the Department of Justice, he litigated tax cases in the federal district courts and the U.S. Court of Federal Claims. For his work representing the government in extended trials involving the IRS's attack on leveraged corporate-owned life insurance as a tax shelter, Mr. Ruchelman received the Attorney General's Distinguished Service Award.

Professional Activities

Mr. Ruchelman recently completed his tenure as Chairman of the Tax Audits and Litigation Committee for the Tax Section of the D.C. Bar. This committee presented monthly panel discussions on hot topics in the tax audits and litigation arena and frequently interacted with IRS and DOJ tax officials. He is also an active member of the American Bar Association Section of Taxation, the Court of Federal Claims Bar Association, and the U.S. Tax Court's J. Edgar Murdoch Inns of Court.